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Internal Revenue Service Tangible Property

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Moving to the U.S.? Have You Planned for the Estate and Gift Taxes?

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It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more

Lasher Holzapfel Sperry & Ebberson PLLC

Washington’s New Capital Gains Tax is Overturned as Unconstitutional

In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

McGlinchey Stafford

Winners And Losers In Like-Kind Exchange Final Regulations

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The Treasury Department and the IRS received 21 written comments in response to the like-kind exchange proposed regulations (see our earlier alert). The recently issued final IRS like-kind exchange regulations adopt some...more

Tonkon Torp LLP

IRS Proposes New 1031 Regulations – Sculptures Are Real Property, Walls Are Not

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The IRS issued Proposed Regulation 117589-18 on June 11, 2020 (the “Proposed Regs”), in response to legislative changes applicable to like-kind exchange transactions (“1031s”). The Proposed Regs address transactions involving...more

Nutter McClennen & Fish LLP

Bonus Depreciation Regulations: A Guide to Tax-Free Income from Capital

Economists maintain that income generated from an expensed capital asset is tax-free. We can’t verify that claim. We can confirm that expensing capital assets enhances investment returns. For this reason, bonus depreciation...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Sullivan & Worcester

Second Round of Treasury Guidance: Key Provisions

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The long-awaited second round of Opportunity Zone-related Proposed Regulations were issued Wednesday, April 17, 2019. It is clear that Treasury’s goals, in its second round of guidance, were to: 1. Provide clarity and/or...more

Katten Muchin Rosenman LLP

Additional Proposed Regulations Issued Regarding Opportunity Zones

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

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On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Stoel Rives LLP

Treasury Issues New Proposed Qualified Opportunity Zone Regulations

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The Department of the Treasury on April 17 released a highly anticipated second round of proposed regulations regarding investments in qualified opportunity zones. The opportunity zone incentive was enacted as part of the Tax...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

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BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Holland & Hart LLP

Proposed Regulations Provide Some Clarity for Opportunity Zone Tax Incentive

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The Treasury Department and Internal Revenue Service issued proposed regulations and other guidance on the new "opportunity zone" tax incentive on October 19, 2018. This tax incentive encourages investment in certain...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

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There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Eversheds Sutherland (US) LLP

IRS announces its “repair” of tangible property examinations

New Campaigns Announced - On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new campaigns continue the IRS’s move to...more

Burr & Forman

The IRS Tax Levy on Social Security Benefits: Does it Last Forever?

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An IRS tax levy is a seizure of a person’s property or rights to property. The IRS then uses the seized property to pay taxes owed. A levy allows the IRS to confiscate a person’s property, which includes cars, boats, real...more

Burr & Forman

Final Version of Tax Reform Act has a Minor Impact on Employee Benefit Programs

Burr & Forman on

In early November, I posted an article entitled “Tax Reform Proposal Nixes Favorable Tax Treatment of Several Employee Benefits”. That article reviewed the Ways and Means Committee’s proposal (H.R. 1, the Tax Reform and Jobs...more

Eversheds Sutherland (US) LLP

Christmas Comes Early: IRS Provides Additional Year of Relief for Taxpayers Seeking to Implement Tangible Property Rules

On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations...more

Eversheds Sutherland (US) LLP

Proposed Regulations Dramatically Change U.S. Federal Tax Treatment of Outbound Transfers of Intangible Property

On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would...more

K&L Gates LLP

New Nevada Commerce Tax Effective July 1, 2015

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While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more

Goulston & Storrs PC

IRS Simplifies Accounting Method Changes Under “Repair Regs”

Goulston & Storrs PC on

In new Rev. Proc. 2015-20, the IRS permits a “small business taxpayer” to use a simplified procedure to change its method of accounting under the final tangible property regulations for tax years beginning on or after January...more

PilieroMazza PLLC

What Every Business Owner Needs to Know About Implementing the New Tangible Property Regulations

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Over the last several years, the IRS has published a series of regulations and rulings that dramatically change how taxpayers must account for the costs of acquiring, repairing, improving and even disposing of tangible...more

Troutman Pepper

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

Troutman Pepper on

Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more

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